Oct. 6, 2022 – In re G.H. (4th Dist., Div. 3, G061166)

The Court of Appeal reverses the order terminating parental rights and remands the matter for the Agency to conduct an adequate ICWA inquiry as to the paternal grandmother. The court notes that the inquiry duty rests with the Agency and the court, not the parent. When there has been no investigation, it cannot be said there is no reason to know whether the child is an Indian child.